Last Updated: May 28, 2021
Siam Piwat Simon Company Limited. (the "Company", "we", "us", or "our") respects the importance of the protection of your rights regarding information relating to any identified or identifiable natural person ("Personal Data") from our products and services. We understand that you would like to receive the required level of protection as required by the Thai applicable data protection laws for how information about you is collected, used, disclosed, and/or transferred outside of Thailand. The information you share with us allows us to provide the products and services that suit your specific needs appropriately, both from the Company, affiliates and subsidiaries in the Siam Piwat group ("Siam Piwat Group"). We provide Personal Data protection measures which include the protection of your Personal Data from being used without your consent beforehand.
We may collect, maintain, and use the following types of information which may include your Personal Data, directly or indirectly, from you, other sources, or from Siam Piwat Group, business partners, and/or communications between us. The specific type of Personal Data collected will depend on the communication and interaction between you and us, including the services or products you desire from us and Siam Piwat Group.
We will only collect, use, and/or disclose sensitive data on the basis of your explicit consent or where permitted by law.
We only collect the information of children, quasi-incompetent persons, and incompetent persons where their parent or guardian has given their consent. We do not knowingly collect information from customers under the age of 20 without their parental consent when it is required, or from quasi-incompetent persons and incompetent persons without their legal guardian’s consent. In the event we learn that we have unintentionally collected personal information from anyone under the age of 20 without parental consent when it is required, or from quasi-incompetent persons and incompetent persons without their legal guardians, we will delete it immediately or collect, use and/or disclose only part that we can rely on other legal bases apart from consent.
2.1. The purpose of which you have given your consent:
2.2 The purposes we may rely on and other legal grounds for collection, use and/or disclosure of your Personal Data
We may also rely on (1) contractual basis, for our initiation or fulfilment of a contract with you; (2) legal obligation, for the fulfilment of our legal obligations; (3) legitimate interest, for the purpose of our legitimate interests and the legitimate interests of third parties; (4) vital interest, for preventing or suppressing a danger to a person’s life, body, or health; and/or (5) public interest, for the performance of a task carried out in the public interest or for the exercising of official authorities or other legal grounds permitted under applicable data protection law as the case may be, depending on the context of the interactions with us.
We may collect, use, and/or disclose your Personal Data for the following purposes:
If you fail to provide your Personal Data when requested, we may not be able to provide our products and services to you.
3.1 Siam Piwat Group
3.2 Our service providers
We may use other companies, agents, or contractors to perform services on behalf of the Company or to assist with the provision of products and services to you. We may share your Personal Data to our service providers or third-party suppliers, including, but not limited to (1) bank and financial institution; (2) logistic and courier service providers; (3) marketing, advertising media, and communications agencies; (4) event organizers; (5) telecommunications and communication service providers; (6) outsourced administrative service providers; (7) data storage and cloud service providers; (8) insurance company; (9) risk management service provider; (10) travel agencies; (11) building renovator; (12) gift card issuance service provider; and/or (13) internet, software, digital media, IT system service providers, and IT support company.
In the course of providing such services, the service providers may have access to your Personal Data. However, we will only provide our service providers with the Personal Data that is necessary for them to perform the services, and we ask them not to use your information for any other purposes. We will ensure the service providers we work with will comply with the requirements under the data protection laws.
3.3 Our business partners
We may transfer your Personal Data to our business partners. We may cooperate with our business partners (e.g., shop tenants, rewarding program partners, credit card partners), whom we may jointly offer products or services, or whose products or services may be offered to you.
3.4 Third party sites
3.5 Third parties required by law
In certain circumstances, we may be required to disclose or share your Personal Data in order to comply with legal or regulatory obligations. This includes any law enforcement agency, court, regulator, government authority or other third parties where we believe it is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals’ personal safety, or to detect, prevent, or otherwise address fraud, security, or safety issues.
3.6 Professional advisors
This includes legal consultants, auditors or other consultants who assist in running our business, and the defending or bringing of any legal claims.
3.7 Assignee of rights and/or obligations
3.8 Other third parties
We may disclose or transfer your Personal Data to third parties or servers located overseas, which the destination countries may or may not have the same data protection standards. We take steps and measures to ensure that your Personal Data is securely transferred and that the receiving parties have in place suitable data protection standards or other derogations as allowed by laws. We will request your consent where consent to cross-border transfer is required by law.
We shall retain your Personal Data for as long as is reasonably necessary to fulfil the purpose for which we obtained it, and to comply with our legal and regulatory obligations. However, we may have to retain your Personal Data for a longer duration, as required by applicable law.
If you visit our websites and applications, we will track, collect, and record certain Personal Data by using cookies or other tracking technology. For the applications, cookies will start tracking when you log into the applications, where cookies will remember you and keep you logged in with your username and password every time you use the application unless you log out. In case we have no control over cookies, we will not collect information from cookies or access to cookies.
We shall use a cache data to record your data. In case you use other devices to connect with our websites or applications, your data may be stored and recorded in form of a cache file, or the part of your data might be duplicated on the computer or mobile device for using next time, provided that we have no control related to the data or access of the cache file.
Subject to applicable laws and exceptions thereof, you may have the following rights to:
1) Right to access: You may have the right to access or request a copy of the Personal Data we are collecting, using, and/or disclosing about you. For your own privacy and security, we may require you to prove your identity before providing the requested information to you.
2) Right to rectification: You may have the right to have incomplete, inaccurate, misleading, or or not up-to-date Personal Data that we collect, use, and disclose about you rectified.
3) Right to data portability: You may have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to send or transfer such Personal Data to another data controller, provided, that (a) such Personal Data shall be Personal Data you have provided to us, and (b) we have obtained your consent for collecting, using, and/or disclosing such Personal Data, or for performing our contract with you.
4) Right to objection: You may have the right to object to certain collection, use, and/or disclosure of your Personal Data, such as objecting to direct marketing.
5) Right to restriction: You may have the right to restrict the use of your Personal Data in certain circumstances.
6) Right to withdraw consent: For the purposes you have consented to our collecting, using, and disclosing of your Personal Data, you have the right to withdraw your consent at any time.
7) Right to deletion: You may have the right to request that we delete or de-identity Personal Data that we collect, use, and disclose about you. However, we are not obligated to do so if we need to retain such data in order to comply with legal obligations or to establish, exercise, or defend legal claims.
8) Right to lodge a complaint: You may have the right to lodge a complaint to the competent authority where you believe our collection, use, and/or disclosure of your Personal Data is unlawful or noncompliant with applicable data protection law.
We maintain appropriate security measures for Personal Data, which cover administrative, technical and physical safeguards in relation to access control to protect the confidentiality, integrity, and availability of Personal Data against any accidental loss or unlawful or unauthorized access, use, alteration, correction or disclosure of Personal Data, in compliance with the applicable laws.
We have implemented measures on controlling access and use of devices for storing and processing Personal Data which are secured and suitable for our collection, use and disclosure of Personal Data. We also have measures on restricting access to Personal Data and the use of storage and processing equipment by imposing users’ access rights, users’ permission rights to the authorized personnel, and users’ duties and responsibilities to prevent unauthorized access, disclosure, perception or unlawful duplication of Personal Data, or theft of device used to store and process Personal Data. This includes measures on the re-examination in relation to access, alteration, erasure, or transfer of Personal Data which are in accordance with methods and channels used to collect, use or disclose Personal Data.